Privacy Policy

Steele does not collect personally identifiable information (“Personal Information”) about individuals through its websites except when such individuals specifically provide such information on a voluntary basis. For example, such Personal Information may be gathered from an event or subscription registration, a survey, a request for publications or information such as Whitepapers, an employment submission (by online form or online resume submission), or from an e-mail sent to a Steele website. Personal Information on individual users will not be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection (except as required by subpoena, search warrant or other legal process or in the case of imminent physical harm to the individual or others).

Notwithstanding any opt-out of promotional information by the user, Steele reserves the right to contact a subscriber regarding account status, changes to the subscriber agreement and other matters relevant to the underlying service and/or the information collected. Users also should be aware that non-personal information and data may be automatically collected through the standard operation of Steele’s internet servers or through the use of “cookies.” “Cookies” are small text files a web site can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and allow a site to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. Cookies are not programs that come onto a user’s system and damage files. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site. If a user does not want information collected through the use of cookies, there is a simple procedure in most browsers that allows the user to deny or accept the cookie feature; however, users should note that cookies may be necessary to provide the user with certain features (e.g., customized delivery of information) available on Steele’s Network. Upon request, Steele will allow any user to “opt out” of further promotional contacts at any time. Additionally, upon request, Steele will use reasonable efforts to allow users to update/correct Personal Information previously submitted which the user states is erroneous to the extent such activities will not compromise privacy or security interests. Also, upon a user’s request, STEELE CIS will use commercially reasonable efforts to functionally delete the user and his or her Personal Information from its database; however, it may be impossible to delete a user’s entry without some residual information because of backups and records of deletions.

In the case of non-promotional contact, Steele offers individuals the opportunity to choose whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. In addition, Steel does not collect or otherwise process sensitive information, defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual.

Steele provides advisory, subscription-based software and due diligence services to its clients. In connection with providing those services, Steele is committed to safeguarding client confidences, including any Personal Information: (i) received from or about our clients or their third-party business associates in the course of an engagement, or (ii) which is hosted on Steele’s software services. Steele personnel are required to hold such information in strict confidence and to use and disclose it only to provide the services for which we are retained. Accordingly, Personal Information obtained from or relating to our clients or their third-party business associates is processed in compliance with the terms and conditions set forth in our client contracts, applicable law, and professional standards.

Steele complies with the EU – U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States. Steele has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Steele commits to resolve complaints about our collection and use of your personal information. Individuals in the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact Steele at: privacy@steeleglobal.com

Steele has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution (ICDR/AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit: http://info.adr.org/safeharbor for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.

You have the right to access your Personal Information by contacting Steele at the link set forth above. Steele may disclose your Personal Information in response to lawful requests by public authorities having jurisdiction over Steele, including to meet national security or law enforcement requirements. In connection with compliance-related due diligence investigations requested by Steele’s clients, Steele may also disclose your personal information to third party investigators under contract with Steele as its agent in local jurisdictions throughout the world. In the event Steele transfers your Personal Data to third parties acting as agents on its behalf, Steele shall remain liable if such third party agent processes your Personal Information in a manner inconsistent with the Privacy Shield Principles. Steele is subject to the investigatory and enforcement powers of the Federal Trade Commission in connection with the processing of your Personal Information under the Privacy Shield Framework and under certain conditions you may have the right to invoke binding arbitration to resolve any claim or dispute relating to the processing of your Personal Information.

The foregoing policies are effective as of June 30, 2017. Steele reserves the right to change this policy at any time by notifying users of the existence of a new privacy statement. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any party.